PAO Symbol

Regulation (EC) No 1223/2009 was adopted on 30 November 2009 and became fully applicable across the EU on 11 July 2013, replacing the earlier Cosmetics Directive 76/768/EEC. Because it was written as a regulation rather than a directive, it applies directly and uniformly in every member state, removing the inconsistencies that arose when the old directive had to be separately transposed into each country's national law.

The PAO labeling requirement, including the open-jar symbol, was introduced as part of this modernization of EU cosmetic safety and labeling rules.

A sealed, unopened cosmetic can remain stable for years, but once opened it is repeatedly exposed to air, light, and contact from fingers or applicators. This exposure can gradually break down a product's preservative system and accelerate oxidation of its ingredients, changing how safe or effective it is in ways a fixed expiry date printed at manufacture cannot capture. PAO addresses that opened-product risk specifically, rather than shelf stability before first use.

Under the regulation, the PAO symbol is only required for products with an unopened shelf life longer than 30 months; products expected to last 30 months or less must instead carry a fixed 'best before' date. The symbol also does not apply to single-use products or to sealed, pressurized formats such as aerosols, where the packaging itself prevents the contents from being exposed to air after use.